ML25273A340
| ML25273A340 | |
| Person / Time | |
|---|---|
| Site: | Kemmerer File:TerraPower icon.png |
| Issue date: | 09/30/2025 |
| From: | George Wilson TerraPower |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| TP-LIC-LET-0458 | |
| Download: ML25273A340 (1) | |
Text
15800 Northrup Way, Bellevue, WA 98008 www.TerraPower.com P. +1 (425) 324-2888 F. +1 (425) 324-2889 September 30, 2025 TP-LIC-LET-0458 Docket Number 50-613 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Document Control Desk
Subject:
Regulatory Engagement Plan for the Kemmerer Unit 1 Operating License Application References:
- 1. TerraPower, LLC, Submittal of the Construction Permit Application for the Natrium Reactor Plant, Kemmerer Power Station Unit 1, March 28, 2024 (ML24088A059).
Pursuant to Title 10 of the Code of Federal Regulations, Part 50 (10 CFR 50), Domestic Licensing of Production and Utilization Facilities, TerraPower, LLC (TerraPower), on behalf of US SFR Owner, LLC (USO), submitted a construction permit application (CPA) to construct a Natrium Reactor Plant1 at the Kemmerer Power Station Unit 1 (KU1) site (Reference 1). The enclosed Regulatory Engagement Plan (REP) is being provided to establish a structured framework for interactions between TerraPower and the US Nuclear Regulatory Commission (NRC) prior to submittal of an operating licensing application for KU1.
The REP is also being submitted to define the scope of activities that qualify for the Reduced Hourly Rate as defined in the Fiscal Year 2025 Final Fee Rule, effective October 1, 2025. In addition to the activities outlined in the enclosure, TerraPower also requests all reviews currently ongoing associated with Reference 1, including the review of 1 Natrium is a TerraPower and GE Vernova Hitachi Nuclear Energy Technology.
September 30, 2025 Page 2 of 2 15800 Northrup Way, Bellevue, WA 98008 www.TerraPower.com P. +1 (425) 324-2888 F. +1 (425) 324-2889 documents incorporated by reference and therefore part of an advanced nuclear reactor construction permit, qualify for the Reduced Hourly Rate.
This letter makes no new or revised regulatory commitments. If you have any questions regarding this submittal, please contact Ian Gifford at igifford@terrapower.com.
Sincerely, George Wilson Senior Vice President, Regulatory Affairs TerraPower, LLC cc:
Mallecia Sutton, NRC Josh Borromeo, NRC Nathan Howard, DOE
Enclosure:
NAT-9408, Revision 0, Regulatory Engagement Plan for the Kemmerer Unit 1 Operating License Application
ENCLOSURE 1 NAT-9408, Revision 0, Regulatory Engagement Plan for the Kemmerer Unit 1 Operating License Application
SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
NAT-1911 Rev. 6 Verify Current Revision Document
Title:
Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Natrium Document No.:
NAT-9408 Rev. No.:
0 Page:
1 of 17 Doc Type:
Report Target Quality Level:
N/A Alternate Document No.:
N/A Alt. Rev.:
N/A Originating Organization:
Licensing Quality Level:
N/A Natrium MSL ID:
Licensing & Permitting Status:
Released Open Items?
N/A Approval Approval signatures are captured and maintained electronically; see Electronic Approval Records in EDMS.
Signatures or Facsimile of Electronic Approval Record attached to document.
NAT-9408 Rev 0 Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Page 2 of 17 Not Confidential Controlled Document - Verify Current Revision SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
REVISION HISTORY Revision No.
Affected Section(s)
Description of Change(s) 0 All Original Issue
NAT-9408 Rev 0 Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Page 3 of 17 Not Confidential Controlled Document - Verify Current Revision SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
TABLE OF CONTENTS 1
INTRODUCTION..................................................................................................................................... 4 1.1 Summary of Strategic Project Approach/Goals.............................................................................. 4 1.2 Objectives....................................................................................................................................... 4 1.3 Approach........................................................................................................................................ 5 2
PROJECT OVERVIEW........................................................................................................................... 5 2.1 Company/Project Structure............................................................................................................ 5 2.2 Technology Summary..................................................................................................................... 5 3
REGULATORY ENGAGEMENT STRATEGY......................................................................................... 6 3.1 Types of Engagement.................................................................................................................... 6 3.2 Communication Protocols............................................................................................................... 6 3.3 Assessing Alignment and Gaps...................................................................................................... 6 3.4 Key Milestones............................................................................................................................... 6 3.5 Key Areas for Engagement............................................................................................................ 6 3.6 Escalation of Issues........................................................................................................................ 6 4
PRE-APPLICATION ENGAGEMENT..................................................................................................... 7 4.1 Identification of Topics.................................................................................................................... 7 4.2 Topics for Pre-Application Engagement Meetings......................................................................... 7 4.3 Prioritization of Topics.................................................................................................................... 8 4.4 Types and Frequency of Interactions............................................................................................. 8 4.5 Continuous Improvement............................................................................................................... 8 4.6 Schedule Considerations................................................................................................................ 8 4.7 Relation to Other Proceedings/Reviews......................................................................................... 8 5
SCHEDULE............................................................................................................................................. 8 5.1 Pre-Application............................................................................................................................... 8 5.2 Application...................................................................................................................................... 9 5.3 Post-Application.............................................................................................................................. 9 6
TABLES................................................................................................................................................. 10 7
ACRONYMS.......................................................................................................................................... 16 8
REFERENCES...................................................................................................................................... 17 LIST OF TABLES Table 6-1: New Topical Reports.................................................................................................................. 10 Table 6-2: Revised Topical Reports............................................................................................................ 11 Table 6-3: Exemptions to Support OLA...................................................................................................... 12 Table 6-4: Meetings, White Papers, and Miscellaneous Engagements...................................................... 13
NAT-9408 Rev 0 Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Page 4 of 17 Not Confidential Controlled Document - Verify Current Revision SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
1 INTRODUCTION The purpose of this Regulatory Engagement Plan (REP) is to establish a structured framework for interactions between the US SFR Owner, LLC (USO), a wholly owned subsidiary of TerraPower, LLC (TerraPower), and the United States Nuclear Regulatory Commission (NRC) to support the timely, efficient, and transparent review of the Natrium Reactor Plant Operating License Application (OLA) at the Kemmerer Power Station Unit 1 site (KU1).1 This REP is submitted as a Qualifying Licensing Project Plan under the Nuclear Energy Innovation and Modernization Act (NEIMA) and the Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy (ADVANCE) Act. This REP includes all activities relating to or supporting the activities described in the following sections of this document. Additional activities may be added as needed.
This REP is intended to:
Facilitate early and frequent communication.
Identify key engagement topics and milestones.
Align expectations regarding scope, content, and schedule of submittals.
Provide a risk-informed and performance-based approach to regulatory interactions.
1.1 Summary of Strategic Project Approach/Goals The approach to the OLA is like that used for the Construction Permit Application (CPA). USO is using the licensing process in Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, (Reference 1) to move from a construction permit to an operating license.
Aspects of the projects approach that could influence or impact the extent of the pre-application, NRC staff review schedule, or the need for NRC staff training and familiarity with the project may include:
Unique approaches with respect to compliance with NRC regulations and guidance and the use of the Licensing Modernization Project The extent that the Natrium Technology represents first-of-a-kind design and unique implementation of previously demonstrated technologies Design review challenges associated with the use of commercial codes and standards Identifying an appropriate scope and depth of information needed for approval 1.2 Objectives The objectives of the REP are to:
Promote Transparency: Ensure NRC staff have timely access to design and licensing information.
1 Natrium is a TerraPower and GE Vernova Hitachi Energy Technology.
NAT-9408 Rev 0 Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Page 5 of 17 Not Confidential Controlled Document - Verify Current Revision SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
Enable Predictability: Establish mutually agreed engagement milestones to support efficient scheduling.
Facilitate A Risk-Informed Review: Focus interactions on safety-significant topics and novel features.
Support Licensing Efficiency: Identify areas where topical reports (TRs), white papers, or pre-application submittals can reduce future review effort.
Build Public Confidence: Demonstrate regulatory rigor and early resolution of safety, security, and environmental issues.
1.3 Approach The REP is expected to be a living document that will be updated and expanded as plans evolve.
As such, USO expects to:
Communicate and seek alignment with NRC staff when changes to the information contained in the REP are needed.
Periodically update the REP.
2 PROJECT OVERVIEW 2.1 Company/Project Structure The Natrium Reactor Plant is a TerraPower and GE Vernova Hitachi (GVH) Nuclear Energy technology that features a sodium-cooled fast reactor (SFR) combined with a molten salt energy storage system.
2.2 Technology Summary The Natrium reactor is a metal-fueled, pool type SFR that takes advantage of the simple and robust safety profile of SFRs to reduce the complexities associated with nuclear design and construction, resulting in a vastly simplified reactor building. The superior heat transfer characteristics of sodium and operating at low pressure permit the use of compact and lightweight equipment, unlike in other reactor types cooled with pressurized water or gas.
The Natrium reactor is coupled to a molten salt loop that transports heat from the nuclear island to the energy island. This minimizes the amount of equipment and structures on the nuclear site and enables load following, coupling to thermal energy storage, and industrial heat applications.
The higher operating temperature and constant thermal output make an ideal match for thermal energy storage using molten salt, a technology that is commercially deployed in the solar industry. Hot sodium from the reactor transfers its heat to intermediate sodium. Heat from the intermediate sodium is then transferred to a molten salt loop, which carries heat off the nuclear island where it can be stored, converted into electricity, or used for industrial process heating.
This decoupled architecture minimizes the size of the nuclear site and allows the reactor to operate at constant conditions while the energy island meets variable energy demands. The Natrium reactor is rated at 840MW thermal. The energy island will have the capability to produce up to 500MW electric.
NAT-9408 Rev 0 Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Page 6 of 17 Not Confidential Controlled Document - Verify Current Revision SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
3 REGULATORY ENGAGEMENT STRATEGY Identifying key topics that need to be resolved early and gaining an understanding of how planned submittals will provide required content and design information is key to a predictable review schedule.
3.1 Types of Engagement Pre-Application Interactions: Technical meetings, site visits, and audits.
Regular Status Meetings: Periodic meetings with NRC staff.
Focused Technical Discussions: On areas that are unique to the Natrium design or that are new to NRC staff.
Document Submittals: Including white papers, TRs, and technical reports.
Document Roadmap Alignment: Early review of chapter outlines of the OLA Final Safety Analysis Report (FSAR).
3.2 Communication Protocols Routine meetings with NRC Project Managers.
Ad hoc meetings with NRC staff to discuss technical and non-technical topics.
Public meetings with NRC staff to discuss topics of interest.
Drop-in visits at either NRC or TerraPower offices or sites.
Written documents provided on the docket, which may include white papers, TRs, and technical reports, among others.
3.3 Assessing Alignment and Gaps Pre-application interactions will be conducted with NRC staff to align on gap resolution not previously identified at the CPA stage.
3.4 Key Milestones Key milestones are major planned activities and decision points that represent significant progress toward licensing and require coordination between USO and the NRC. Achieving key milestones requires identifying and resolving potential licensing issues early. To this end, a list of anticipated milestones has been developed and appears further on in this document.
3.5 Key Areas for Engagement Major design changes, white papers, TRs, and technical reports are expected to become key areas for engagement. To this end, a list has been developed and appears further on in this document.
3.6 Escalation of Issues
NAT-9408 Rev 0 Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Page 7 of 17 Not Confidential Controlled Document - Verify Current Revision SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
It is expected that USO and NRC staff will develop a process for escalating issues that arise during the review.
4 PRE-APPLICATION ENGAGEMENT USO will facilitate pre-application engagements (e.g., teleconferences, video conferences, and face-to-face meetings) with the NRC staff. The primary objectives of these engagements are to identify, assess, and mitigate regulatory risks. The primary benefits for planning these engagements are alignment on content, scope, and level of detail, and to reduce regulatory uncertainty. USO will coordinate with NRC staff to establish an appropriate engagement schedule of open and closed meetings until application submittal. The purpose of these meetings is to ensure NRC staff has timely and accurate information to complete its safety and environmental determinations with respect to agency resource availability. USO understands the need to notify the public of agency meetings and will support efforts for early meeting notifications.
In coordination with NRC staff, topics can be prioritized and interactions optimized to address those issues most important to the overall project plan.
4.1 Identification of Topics The various tables near the end of this document contain milestones and lists of topics that have the potential to warrant engagement with NRC staff during the pre-application process:
Table 6-1: New Topical Reports - Lists new TRs that will be required for the OLA.
Table 6-2: Revised Topical Reports - Lists TRs that were reviewed during the CPA but that have since been revised and will require review for the OLA.
Table 6-3: Exemptions to Support OLA - Contains a list of anticipated/known exemptions that will be required for OLA.
Table 6-4: Meetings, White Papers, and Miscellaneous Engagements - Contains a list of other documents or activities that may require review by NRC staff.
The NRC staff will be notified if additional topics are needed for planning and budget purposes.
Timely pre-application engagement for each identified topic is important to keep NRC staff informed and aligned on schedule. Some of the pre-application engagements are estimated based on current information and are subject to change as the project progresses.
Topics important to address in pre-application engagements are selected because of a potential tie to a:
deviation from guidance; generic or industry issue; design-specific issue; or site-specific issue.
4.2 Topics for Pre-Application Engagement Meetings
NAT-9408 Rev 0 Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Page 8 of 17 Not Confidential Controlled Document - Verify Current Revision SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
It is anticipated that USO and NRC staff will perform an initial review of the items listed in this REP to determine those desired to be scheduled for engagement. Those items will then become the focus of the initial set of pre-application engagements. Topics and issues may be added or removed as deemed necessary and the REP will be revised and re-issued periodically.
4.3 Prioritization of Topics Topics for pre-application interaction are prioritized based on complexity; schedule, licensing timelines, and resource availability. Early interactions with NRC staff and management will focus on the selection of topics with potentially broad programmatic impact such as:
Quality Assurance program and procedure development; issues that could impact long-lead material and equipment procurement; fuel qualification; and testing.
4.4 Types and Frequency of Interactions The types and frequency of interactions anticipated between USO and NRC staff can be found in Sections 3.1 and 3.2 and may include phone calls, teleconferences, or meetings to solicit feedback on proposed technical approaches, or audits/inspections of the engineering information, testing facilities, etc. to support the OLA.
4.5 Continuous Improvement The REP will be treated as a living document and updated as project milestones, NRC feedback, or design changes warrant.
4.6 Schedule Considerations Pre-application engagements will establish a schedule of meetings and submittals, and the timing/duration of NRC staff reviews and public meetings. Additionally, the expectations for communicating changes to the schedule and scope will also be established.
4.7 Relation to Other Proceedings/Reviews The OLA will build on the information provided in the CPA.
5 SCHEDULE Sections 3 and 4 outline general considerations for pre-application interactions and document submittals, including periodic schedule reviews and management-level reviews of schedule performance following submittal and docketing of the application. Topics may be considered for inclusion or revision during the course of the REP and were used in developing the tables that follow.
The schedule will consist of the following phases:
5.1 Pre-Application Routine project management meetings
NAT-9408 Rev 0 Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Page 9 of 17 Not Confidential Controlled Document - Verify Current Revision SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
Technical exchanges, including issue identification and resolution meetings and NRC staff familiarization sessions Establishment of long-lead programmatic items Submittal of TRs, technical reports, white papers, etc.
Pre-application site visits, and audits Pre-application readiness assessment 5.2 Application Resolution of readiness assessment issues Finalization and submittal of the application Acceptance review 5.3 Post-Application Docketing and NRC notifications Establishment of review schedules, including Advisory Committee on Reactor Safeguards (ACRS) interactions Audits and inspections Periodic management reviews of schedule performance
NAT-9408 Rev 0 Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Page 10 of 17 Not Confidential Controlled Document - Verify Current Revision SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
6 TABLES Table 6-1: New Topical Reports Topic Timeframe*
Scope and Desired Outcome Comprehensive Vibration Assessment Program (CVAP) 26Q1 SCOPE: Discuss CVAP TR and methods of conforming to Regulatory Guide 1.20.
OUTCOME: NRC approval of the program described.
Sodium-Salt Interactions 26Q2 SCOPE: Describe the sodium-salt interaction (quantitative and testing).
Propose approach to preventing the interaction in Sodium-Salt Heat Exchanger design.
OUTCOME: NRC approval of the methodology described for defining the sodium-salt interaction and the preventative features of the SHX design.
Technical Specifications &
Technical Requirements Manual Methodology 26Q3 SCOPE: Topical Report outlines the method used to develop the Tech Specs and the Technical Requirements Manual OUTCOME: NRC approval of the method described.
Criticality Methodology 26Q3 SCOPE: Topical report covers each spent fuel storage location (e.g., IVS, EVST, SFP) criticality methodology and results.
OUTCOME: NRC approval of the method described and the Natrium core assembly storage locations.
Core Design 26Q3 SCOPE: Discuss strategy of providing detailed core design information in a new TR.
OUTCOME: NRC understanding, and approval of the Natrium reactor core design.
Plant-Referenced Simulator Design and V&V 26Q3 SCOPE: Discuss the methodologies for conducting major activities (e.g.,
sampling of operational conditions, verification and validation, simulator fidelity, ISV, human engineering discrepancy resolution, and malfunctions).
OUTCOME: NRC staff approval of defined activities necessary for having an approved plant-referenced simulator for performing control manipulations so that Operator Licensing training and examination can be completed without the need for a deferral.
Natrium Scaling Methodology 26Q3 SCOPE: Describe the overall methodology for scaled testing to support the Natrium design and Probabilistic Risk Assessment (PRA) and safety analysis assumptions.
OUTCOME: NRC approval of the overall approach to scaled testing.
Software Life Cycle 26Q4 SCOPE: Describe the overall methodology software life cycle.
OUTCOME: NRC approval of the method described.
- Approximate timeframe, subject to change
NAT-9408 Rev 0 Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Page 11 of 17 Not Confidential Controlled Document - Verify Current Revision SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
Table 6-2: Revised Topical Reports Topic Timeframe*
Scope and Desired Outcome Update to NAT-9395 Partial Flow Blockage Methodology 26Q3 SCOPE: Provide general updates to the TR and document previous plan execution. Will provide information related to adequacy of method following benchmarks, scaling, and experiments.
OUTCOME: NRC approval of the methodology.
Update to NAT-9393 Reactor Stability Methodology 26Q3 SCOPE: Provide general updates to the TR. Additional Natrium values for the report were in development at prior revision submittal, new revision will capture these.
OUTCOME: NRC approval of the methodology..
Update to NAT-4950 I&C Architecture and Design Basis Topical Report 26Q4 SCOPE: Brief staff on the updates to Instrumentation and Controls (I&C) architecture based on detailed design.
OUTCOME: NRC understanding and approval of the I&C architecture.
Update to NAT-9394 DBA Transient Methods for Events with Radiological Release 26Q4 SCOPE: Provide general updates to the TR and document previous plan execution. Will provide information related to adequacy of method following benchmarks, scaling, and experiments.
OUTCOME: NRC approval of the methodology.
Update to NAT-9390 DBA In-Vessel Transient Methodology for Events without Radiological Release 26Q4 SCOPE: Provide general updates to the TR and document previous plan execution. Will provide information related to adequacy of method following benchmarks, scaling, and experiments.
OUTCOME: NRC approval of the methodology Update to NAT-9392 (TP-LIC-RPT-0003)
Radiological Source Term Methodology 26Q4 SCOPE: Provide general updates to the TR and document previous plan execution. Will provide information related to adequacy of method following benchmarks, scaling, and experiments.
OUTCOME: NRC approval of the methodology.
Update to NAT-2965 Human Factors Engineering 27Q1 SCOPE: Provide general updates to the TR.
OUTCOME: NRC approval of the approach described in the report.
Update to NAT-2806 Fuel and Control Assembly Qualification 27Q2 SCOPE: Provide general updates to the TR. Revision will document results from qualification testing and include considerations for Type 1B fuel.
OUTCOME: NRC approval of the qualification plan.
- Approximate timeframe, subject to change
NAT-9408 Rev 0 Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Page 12 of 17 Not Confidential Controlled Document - Verify Current Revision SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
Table 6-3: Exemptions to Support OLA Topic Timeframe*
Scope and Desired Outcome Technical Specifications &
Technical Requirements Manual Approach 26Q1 SCOPE: Framework and strategy, PRA Information Use in Risk-Informed Technical Specifications, Scoping Process (including TRM), exemption from 50.36.
OUTCOME: NRC staff's understanding and feedback on TS strategy and scope of exemption.
Physical Security Plan 26Q2 SCOPE: Discuss physical security plan regulatory compliance and possible exemption.
OUTCOME: NRC understanding and feedback on physical security plan and exemption scope.
Elimination of the Shift Technical Adviser 26Q3 SCOPE: Discuss the approach to the exemption eliminating the STA from the Main Control Room minimum staffing.
OUTCOME: NRC understanding and feedback on the exemption approach.
Control Room Staffing 27Q3 SCOPE: Propose Control Room staffing plan and details for exemption from STA requirements and potentially 50.54(m).
OUTCOME: NRC understanding and feedback on the staffing plan and exemption justification.
TIRICE Implementation 27Q4 SCOPE: Approach to implementing Technology-Inclusive Risk-Informed Change Evaluation (TIRICE) and scope of required exemption to 50.59.
OUTCOME: NRC staff's understanding and feedback on approach and exemption scope.
- Approximate timeframe, subject to change
NAT-9408 Rev 0 Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Page 13 of 17 Not Confidential Controlled Document - Verify Current Revision SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
Table 6-4: Meetings, White Papers, and Miscellaneous Engagements Topic Timeframe*
Scope and Desired Outcome Technical Specifications &
Technical Requirements Manual Approach 26Q1 SCOPE: Meeting & White Paper; Framework and strategy, PRA Information Use in Risk-Informed TS, Scoping Process (including TRM),
exemption from 50.36.
OUTCOME: NRC staff's understanding and feedback on TS strategy and scope of exemption.
Fire Protection (FP) 26Q1 SCOPE: Meeting & White Paper; Approach to fire protection for Natrium, KU1 Fire Protection Plan (including fire brigade strategy), plan for FHA, FPRA, SSA.
OUTCOME: NRC understanding and feedback on overall FP strategy.
Nuclear Methods Benchmark Validation and Uncertainty Calculations 26Q1 SCOPE: Meeting & White Paper; Describe Natrium nuclear method FOMs, V&V, historical benchmarks, and plans.
OUTCOME: NRC understanding and feedback on use of historical data to validate neutronics codes.
Emergency Action Level Methodology 26Q1 SCOPE: Meeting & White Paper; Propose Natrium-specific Emergency Action Level Methodology.
OUTCOME: NRC understanding and feedback on a Natrium-specific methodology using similar approach of Nuclear Energy Institute (NEI) 07-01 and NEI 99-01 Rev 7.
Fuel Handling Design and Construction Code Application for IVTM and FTL 26Q1 SCOPE: Meeting; Discussion current code application for the design of the (In-Vessel Transfer Machine (IVTM) and Fuel Transfer Lift (FTL).
OUTCOME: NRC feedback on code application for the IVTM and FTL.
Seismic Isolation System design and qualification 26Q1 SCOPE: Meeting; Present seismic isolation system design and qualification plan details.
OUTCOME: NRC understanding and feedback on Seismic Isolation System design details and qualification plan.
RAC Method Modeling and Validation 26Q2 SCOPE: Meeting; RAC plan for method code validation and acceptance including discussion of known phenomena.
OUTCOME: NRC understanding and feedback on strategies to address important phenomena and V&V.
Use of Computational Fluid Dynamics (CFD) in lieu of testing 26Q2 SCOPE: Meeting; Describe strategies for determining acceptable use of CFD to supplement historical data and testing for core thermal hydraulics.
OUTCOME: NRC understanding and feedback on acceptability of using CFD for methods to supplement testing.
E-plan 26Q2 SCOPE: Meeting; Description of the E-plan approach and regulatory guidance used to implement 50.160.
OUTCOME: NRC understanding and feedback on the approach to implementing 50.160 in the E-plan using available guidance.
NAT-9408 Rev 0 Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Page 14 of 17 Not Confidential Controlled Document - Verify Current Revision SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
Topic Timeframe*
Scope and Desired Outcome Offsite Dose Calculation Manual (ODCM) 26Q2 SCOPE: Meeting; Propose approach to ODCM using NEI 07-09A template, including Radiological Environmental Monitoring Program, and Natrium-specific dose calculation methodology.
OUTCOME: NRC understanding and feedback on how Natrium complies with 50.36a, RG 1.21 Rev 3, and the specific methodology for dose calculation.
Technical Specifications &
Technical Requirements Manual - Resulting Requirements 26Q2 SCOPE: Meeting; Discuss the final content of the proposed technical specifications and items that were screened out of the technical specification scope.
OUTCOME: NRC staff understanding of the content of the proposed technical specifications that will be submitted with the OLA.
PITAP 26Q3 SCOPE: Meeting; Describe the planned scope of pre-operational and initial startup testing to be included in the FSAR. Compare to Regulatory Guide (RG) 1.68 requirements.
OUTCOME: NRC understanding and feedback on expectations for the level of detail and amount of testing included in the FSAR/licensing basis.
Use of digital components in I&C design 26Q4 SCOPE: Meeting; Discuss the digital components that have been identified for I&C systems based upon detailed design and procurement.
Provide detailed description of industry codes and standards being used to comply with regulation and conform to regulatory guidance.
OUTCOME: NRC understanding and feedback on the methods being used to comply with regulation and conform to regulatory guidance.
Cyber Security Plan 27Q1 SCOPE: Meeting; Discuss conformance of cyber security plan to industry guidance.
OUTCOME: NRC understanding and feedback on cyber security plan.
30/40/70 Licensing Considerations 27Q1 SCOPE: Meeting; Propose approach to licensing radioactive materials for receipt prior to OLA issuance including program staging and general timelines.
OUTCOME: NRC understanding and feedback on approach to license, receive, and possess materials through 10 CFR Parts 30, 40, and 70.
Design changes since PSAR 27Q1 SCOPE: Meeting; Brief NRC on major design changes since the CP was issued.
OUTCOME: NRC awareness of changes to the design to be included in the FSAR.
Licensing Exam Standard /
Knowledge and Abilities (K&A) Catalog 27Q1 SCOPE: Meeting; Develop the requirements for conducting Operator Licensing examinations.
OUTCOME: Provide NRC with the information needed to be used for consideration for input to the KU1 section of NUREG-1021 (i.e., Natrium-specific K&A Catalog) to support an exam early in 2028. Gain alignment on the exemptions from the requirements in NUREG-1021 involving exam validation, exam prep, comparable facilities, required control manipulations, quantitative attributes, criteria for critical tasks, and use of part-task/limited scope simulator, among others.
NAT-9408 Rev 0 Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Page 15 of 17 Not Confidential Controlled Document - Verify Current Revision SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
Topic Timeframe*
Scope and Desired Outcome ER Updates 27Q1 SCOPE: Meeting; Present a comparison of the CPA Final Environmental Impact Statement (FEIS) to updated OLA Environmental Report (ER) content. Address commitments made in CPA ER/FEIS.
OUTCOME: NRC understanding of what will be included as an Environmental Report supplement and receive feedback.
Outcome of R&D 27Q1 SCOPE: Meeting; Discuss the results of the R&D items described in Preliminary Safety Analysis Report (PSAR) Chapter 13.
OUTCOME: NRC understanding of the R&D and how results were integrated into design and analyses.
PRA Peer Review 27Q1 SCOPE: Meeting; Discuss the results of the Peer Review and discuss Facts and Observations, including closure plans.
OUTCOME: NRC understanding of the Peer Review results and Facts and Observations.
PRA Updates 27Q2 SCOPE: Meeting; Discuss Methodologies for Seismic, Fire, High Winds, and Internal Flooding. Highlight where existing non-Light-Water Reactor or Light-Water Reactor guidance does not apply.
OUTCOME: NRC understanding and feedback on the methods being used for the external hazard PRAs.
10 CFR 50.155 Compliance Strategy 27Q2 SCOPE: Meeting; Discuss method for compliance with 10 CFR 50.155.
OUTCOME: NRC understanding and feedback on implementation of 10 CFR 50.155 for new technology.
Safety Analysis updates 27Q2 SCOPE: Meeting; Update NRC on major analysis, Licensing Basis Events, and safety classification changes since the CP was issued.
OUTCOME: NRC awareness of how changes to design affect safety analysis results.
Generic Technical Guidelines (GTG) 27Q2 SCOPE: Meeting; Describe the overall approach to generating Generic Technical Guidelines that will be used as the basis for plant specific technical guides used for EOPs.
OUTCOME: NRC understanding and feedback prior to GTG submittal.
- Approximate timeframe, subject to change
NAT-9408 Rev 0 Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Page 16 of 17 Not Confidential Controlled Document - Verify Current Revision SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
7 ACRONYMS Acronym Definition ACRS Advisory Committee on Reactor Safeguards ADVANCE Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy CFD Computational Fluid Dynamics CP Construction Permit CPA Construction Permit Application CVAP Comprehensive Vibration Assessment Program DEIS Draft Environmental Impact Statement DOE Department of Energy EIS Environmental Impact Statement ER Environmental Report FEIS Final Environmental Impact Statement FP Fire Protection FTL Fuel Transfer Lift FSAR Final Safety Analysis Report FSER Final Safety Evaluation Report GTG Generic Technical Guidelines GVH GE Vernova Hitachi I&C Instrumentation and Controls IVTM In-Vessel Transfer Machine NEI Nuclear Energy Institute NEIMA Nuclear Energy Innovation and Modernization Act NRC Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual OLA Operating License Application PRA Probabilistic risk assessment PSAR Preliminary Safety Analysis Report RAI Requests for additional information REP Regulatory Engagement Plan RG Regulatory Guide SEIS Supplemental Environmental Impact Statement SFR Sodium-cooled fast reactor TIRICE Technology-Inclusive Risk-Informed Change Evaluation
NAT-9408 Rev 0 Regulatory Engagement Plan for the Kemmerer Unit 1 Natrium Reactor Plant Operating License Application Page 17 of 17 Not Confidential Controlled Document - Verify Current Revision SUBJECT TO DOE COOPERATIVE AGREEMENT NO. DE-NE0009054 Copyright © 2025 TerraPower, LLC. All rights reserved.
8 REFERENCES
- 1. United States Code of Federal Regulations, Domestic Licensing of Production and Utilization Facilities, Part 50, Chapter I, Title 10, Energy.
- 2. Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy (ADVANCE) Act of 2024, Public Law 118-67, 118th Congress.
- 3. Nuclear Energy Innovation and Modernization Act (NEIMA), Public Law 115-439, 115th Congress.
End of Document